EU NI Protocol May Pave Way for Financial Services Agreement

Published / Last Updated on 02/03/2023

The UK and EU have reached an agreement to make changes to the Northern Ireland protocol when moving goods, services and parcels between the UK mainland and Northern Ireland.  This is now known as ‘The Windsor Framework’.

What is the Windsor Framework?

Reduced the number of checks on goods moving between the UK mainland and Northern Ireland with two ‘lanes’ to be created at ports:

  • Green lane for goods that will remain in Northern Ireland with checks and paperwork scrapped.
  • Red lane for goods which may be sent on from the mainland to the EU i.e., into the Republic of Ireland with customs checks to remain.
  • Northern Ireland will no longer have to follow EU VAT rules on alcohol duty and VAT.
  • Chilled meats and other products moving between Northern Ireland and the UK mainland will no longer be banned.

Opens Doors to Cross Border Finance?

Many of you may not be aware that financial services were not included in the Brexit Trade Agreement.  Currently, there are 5 Memorandums of Understanding (MoU) in place between the UK’s Financial Conduct Authority (FCA) and EU regulators.  For this website, this meant that we could no longer ‘passport’ financial advisory services into Europe.

Currently, as experienced expat and international financial advisers, we cannot promote services to Europe e.g., many British Expats and Foreign Nationals have UK pensions, but it is difficult to get advice on them given EU advisers cannot advise on UK pensions and UK advisers cannot advise people resident in Europe.  In certain circumstances we are still able to help provide advice if contact with us was initiated by people overseas i.e., reverse solicitation and not the other way around i.e. us soliciting for business in EU.

Reverse solicitation (you approach us) and delegated authority (EU regulators delegate regulatory authority for their residents with UK pensions and investments to the FCA) are both included in the MoUs.  Some countries are honouring this already in a spirit of co-operation (Germany, Spain, Ireland and more) whereas as others are not (France and Finland).  We have this in writing from the various regulators and are awaiting more replies.


With the Northern Ireland protocol hopefully resolved to suit all parties, it is now hoped that the UK and EU can now work on trade agreements for finance and research.  Let's hope so.

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